Course of Action
What is the best course of action to take when a policy has changed by a regulatory agency which affects the processing of documents or changing your policies and/or procedures. What is the general timeframe in which to implement these changes?
Most policy changes include guidance on effective dates. Having said that, often there is a "no later than" date for such changes and it may be more beneficial to make the effective date align with certain operational time frames. For example, a certain term start date may be best for an implementation effective date if it is within the compliance boundary. Some regulations require implementing such change for the entire student body while others are tied to academic years, award years, or other time frames. Most changes will require review on the best way to implement within compliance guidelines without causing disruption to operations or the ability to effective track for audit and review processes.
I think we need to inform the key managers of this changes and they will pass it over to their staff. Once the new policy has changed we need to act on it right away, the more time we have to learn and to adapt to it, the less finding will have. The key on this is a good communication among the staff and Campus President.
Communication is certainly key. In addition to implementing policy changes, it is also important to track policies with some form of version control and effective dates. Knowing what policy WAS in place during an audit with an older file is as critical as understanding the current policy.
The best course of action is to learn what the policy changes are and how they affect your institution's current policies and procedures.
Communicate these changes to everyone in the institution who may be affected, including those that they don't directly affect. Then, get together to discuss how to implement these changes throughout the organization.
Also, create new internal audit processes to make sure these changes are compliant.
The timeframe of the implementation will be determined by the regulatory agency.
All changes should be vetted through your financial aid consultant or legal cousel.
I agree. When new policies are implemented they need attended to in a timely manner.
I agree, it can sometimes take time to adapt to changes in procedures. The sooner you begin working on those changes you will be in a better position to know they have been implemented once the final date arrives. Communication between managers and staff is vital in making sure this transition goes through smoothly.
Amber,
Well said. One of the challenges I am hearing from schools is that they try to get ahead by working on changes and then the rules change and/or the guidance takes it in a slightly different direction than how the regulation was originally interpreted.
Traci Lee
Michele, I agree with everything you said, well put!
An interesting thing to consider with new regualtions, though, is that there is not always a guarantee that they will actually be implemented, as seen by the recent Gainful Employment Regulations that were struck down.
How should we prepare for policy changes when there's a chance it will not even be put into effect?
Corrie,
I would rather be prepared and put things aside than to be caught unprepared when deadlines hit. But, I recognize the huge administrative burden that goes with implementation of regulations.
Traci Lee
I agree that it is better to be prepared regarding policies that are being proposed, even if there is a chance they might not be implemented.
I believe that many times the lack of communications between administration and key department heads is exactly what causes non-compliance not how hard or how complicated the change is...I am starting a routing process that rather forces action. As soon as a change is announced, with or without firm deadlines, I will send an email with the pertinent information cut and pasted (or in total depending on the size) and ask for response from each key person within 5 days, in person. Once established that the change is important and is required, and I've heard from the key people, I establish a timeline of action with a preliminary meeting if necessary and a meeting after implementation. I will ask for sign off dates when each stage is accomplished, so we have a history of the change process. I'll let you know how that goes!
Patricia,
I concur that communication is the key to compliance involving multiple departments. I applaud your efforts to ensure each area handles their respective actions.
Traci Lee
This is true. It is also critical because of the inevitable turnover in faculty. Having communication as well as documentation of the old and new versions/effective dates will eliminate some confusion with the process.
Jackie,
Excellent points. I cannot tell you how many times I have seen colleges struggle to determine effective dates after-the-fact.
Traci Lee
